Re:Draft Air Pollution Permit-To-Install

2/23/2009

Sue Ahrmann

YUSA CORPORATION

151 Jamison Rd. SW

Washington C.H., OH 43160

RE:DRAFT AIR POLLUTION PERMIT-TO-INSTALL

Facility ID: 0124010098

Permit Number: P0103947

Permit Type:Initial Installation

County: Fayette

Dear Permit Holder:

A draft of the Ohio Administrative Code (OAC) Chapter 3745-31 Air Pollution Permit-to-Install for the referenced facility has been issued for the emissions unit(s) listed in the Authorization section of the enclosed draft permit. This draft action is not an authorization to begin construction or modification of your emissions unit(s). The purpose of this draft is to solicit public comments on the permit. A public notice will appear in the Ohio EPA Weekly Review and the local newspaper, The Record Herald. A copy of the public notice and the draft permit are enclosed. This permit has been posted to the Division of Air Pollution Control (DAPC) Web page in Microsoft Word and Adobe Acrobat format. Comments will be accepted as a marked-up copy of the draft permit or in narrative format. Any comments must be sent to the following:

Andrew Hall
Permit Review/Development Section
Ohio EPA, DAPC
122 South Front Street
Columbus, Ohio 43215 / and / Ohio EPA DAPC, Central District Office
50 West Town Street, 6th Floor
P.O. Box 1049
Columbus, OH 43216-1049

Comments and/or a request for a public hearing will be accepted within 30 days of the date the notice is published in the newspaper. You will be notified in writing if a public hearing is scheduled. A decision on issuing a final permit-to-install will be made after consideration of comments received and oral testimony if a public hearing is conducted. Any permit fee that will be due upon issuance of a final Permit-to-Install is indicated in the Authorization section. Please do not submit any payment now. If you have any questions, please contact Ohio EPA DAPC, Central District Office at (614)728-3778.

Sincerely,

Michael W. Ahern, Manager

Permit Issuance and Data Management Section, DAPC

Cc:U.S. EPA

Ohio EPA-CDO; Kentucky

Fayette County

PUBLIC NOTICE

Issuance Of Draft Air Pollution Permit-To-Install

YUSA CORPORATION

Issue Date: 2/23/2009

Permit Number: P0103947

Permit Type: Initial Installation

Permit Description: Installation of seven new adhesive application machines. Synthetic minor restrictions to use an RTO with PTE are necessary to restrict VOC potential emissions below major NSR thresholds.

Facility ID: 0124010098

Facility Location:YUSA CORPORATION

151 Jamison Rd. SW,

Washington Court House, OH 43160

Facility Description: Motor Vehicle Steering and Suspension Components (except Spring) Manufacturing

Chris Korleski, Director of the Ohio Environmental Protection Agency, 50 West Town Street, Columbus Ohio, has issued a draft action of an air pollution control permit-to-install (PTI) for an air contaminant source at the location identified above on the date indicated. Installation of the air contaminant source may proceed upon final issuance of the PTI. Comments concerning this draft action, or a request for a public meeting, must be sent in writing no later than thirty (30) days from the date this notice is published. All comments, questions, requests for permit applications or other pertinent documentation, and correspondence concerning this action must be directed to Benjamin Halton at Ohio EPA DAPC, Central District Office, 50 West Town Street, 6th Floor P.O. Box 1049 or (614)728-3778. The permit can be downloaded from the Web page:

Permit Strategy Write-Up

Permit Number: P0103947

Facility ID: 0124010098

Permit Strategy Write-Up

Check all that apply:

Synthetic Minor Determination

Netting Determination

Source Description:

Proposed installation of 7 newadhesive application machines (K061, K062, K063, K064, K065, K066 and K067). Each line consists of the application of a primer followed by an electric dryer followed by the application of a cover-coat followed by another electric dryer. Thespray application for each of these units will take place within a permanent total enclosure that vents all VOC emissions to a regenerative thermal oxidizer. Particulate emissions are controlled through the use of a dry filtration system. The units are considered as part of the affected source with respect to 40 CFR Part 63, subpart MMMM for Surface Coating of Miscellaneous Metal Parts. The requirement to operate the RTO is necessary to avoid Major NSR for VOC and may be necessary to demonstrate compliance with the applicable requirements of subpart MMMM (the facility has chosen the “emissions rate with add-on controls” option for demonstrating compliance with the MMMM subpart and may use the control efficiency of the RTO if all of the subpart requirements are met).

Facility Emissions and Attainment Status:

YUSA Corporation is a Title V facility located within Fayette County. Fayette County is designated as “Attainment” for all criteria pollutants regulated under the CAA. The installation of these seven coating operations represents a 4.71 TPY VOC increase in potential emissions for the facility. The following table identifies the potential particulate and VOC emissions before and after controls:

Major NSR Applicability

Uncontrolled (tpy) / Controlled (tpy)
VOC / PE / VOC / PE
K061 / 27.40 / 1.84 / 0.27 / 0.092
K062 / 71.49 / 0.59 / 0.71 / 0.029
K063 / 80.69 / 7.69 / 0.81 / 0.385
K064 / 29.39 / 2.34 / 0.29 / 0.117
K065 / 22.17 / 2.87 / 0.22 / 0.144
K066 / 71.49 / 5.28 / 0.71 / 0.264
K067 / 170.47 / 12.20 / 1.70 / 0.610
Total / 473.05 / 32.81 / 4.71 / 1.64

As identified in the table above, use of the PTE and RTO are necessary to limit VOC emissions below Major NSR thresholds.

BAT Applicability

VOCcontrolled (tpy) / PEcontrolled (tpy) / NOx (tpy) / SO2 (tpy) / CO (tpy)
RTO / 0.18 / 0.26 / 3.65 / 0.022 / 3.05
K061 / 0.27 / 0.092
K062 / 0.71 / 0.029
K063 / 0.81 / 0.385
K064 / 0.29 / 0.117
K065 / 0.22 / 0.144
K066 / 0.71 / 0.264
K067 / 1.70 / 0.610

Emissions from the combustion of natural gas in the RTO were calculated using AP-42 emissions factors from table 1.4-1 for an 8.5 MMBtu burner. As identified in the table above, the uncontrolled potential NOx, SO2 and CO emissions are below 10 tpy and therefore BAT does not apply and the controlled potential emissions for particulate and VOCs (for the RTO emissions combined with any individual EU emissions) are also below 10 tpy and therefore BAT does not apply.

Source Emissions:

The following table identifies the controlled particulate emissions from each EU used to determine compliance with OAC 3745-17-11(B):

Application Rate (gal/hr) / Solids Content (% volume) / Solid Density (lbs/gal) / Transfer Efficiency / Control Efficiency / PE (lbs/hr)
C205 / C6225 / C205 / C6225 / C205 / C6225
K061 / 0.24 / 0.21 / 0.1365 / 0.1622 / 14.77 / 13.20 / 55% / 95% / .021
K062 / 0.66 / 0.62 / 0.1365 / 0.1622 / 14.77 / 13.20 / 95% / 95% / .007
K063 / 0.74 / 0.67 / 0.1365 / 0.1622 / 14.77 / 13.20 / 40% / 95% / .088
K064 / 0.36 / 0.21 / 0.1365 / 0.1622 / 14.77 / 13.20 / 55% / 95% / .027
K065 / 0.34 / 0.29 / 0.1365 / 0.1622 / 14.77 / 13.20 / 50% / 95% / .033
K066 / 0.66 / 0.62 / 0.1365 / 0.1622 / 14.77 / 13.20 / 55% / 95% / .060
K067 / 1.52 / 1.44 / 0.1365 / 0.1622 / 14.77 / 13.20 / 55% / 95% / .138

The following tables identify the controlled hourly VOC emissions from each EU and the hourly solids consumed used to determine compliance with OAC 3745-21-09(U)(1)(i):

Coatings VOC rate (lb/hr) / Thinners VOC rate (lb/hr) / Combined VOC rate (lb/hr) / Control Efficiency / Controlled VOC(lb/hr)
C205 / C6225 / MIBK / Toluene
K061 / 1.40 / 1.26 / 1.97 / 1.63 / 6.26 / 99% / .063
K062 / 3.86 / 3.77 / 4.27 / 4.42 / 16.32 / 99% / .163
K063 / 4.32 / 4.01 / 2.75 / 7.34 / 18.42 / 99% / .184
K064 / 2.11 / 1.28 / 1.31 / 2.01 / 6.71 / 99% / .067
K065 / 1.99 / 1.75 / 0.51 / 0.81 / 5.06 / 99% / .051
K066 / 3.86 / 3.77 / 4.27 / 4.42 / 16.32 / 99% / .163
K067 / 8.91 / 8.71 / 10.65 / 10.65 / 38.92 / 99% / .389
Application Rate (gal/hr) / Solids Content (% volume) / Total solids (gal/hr) / Controlled VOC(lb/hr) / Max VOC/gal coating solids
C205 / C6225 / C205 / C6225
K061 / 0.24 / 0.21 / 0.1365 / 0.1622 / .07 / .063 / 0.90
K062 / 0.66 / 0.62 / 0.1365 / 0.1622 / .19 / .163 / 0.86
K063 / 0.74 / 0.67 / 0.1365 / 0.1622 / .21 / .184 / 0.88
K064 / 0.36 / 0.21 / 0.1365 / 0.1622 / .08 / .067 / 0.84
K065 / 0.34 / 0.29 / 0.1365 / 0.1622 / .09 / .051 / 0.57
K066 / 0.66 / 0.62 / 0.1365 / 0.1622 / .19 / .163 / 0.86
K067 / 1.52 / 1.44 / 0.1365 / 0.1622 / .44 / .389 / 0.88

Conclusion:

The terms and conditions contained within PTI P0103947 are sufficient to ensure compliance with all state

and federal regulations.

Please provide additional notes or comments as necessary:

None

Total Permit Allowable Emissions Summary(for informational purposes only):

Pollutant / Tons Per Year
VOC / 4.71
PE / 16.89

State of Ohio Environmental Protection Agency

Division of Air Pollution Control

DRAFT

Air Pollution Permit-to-Install

for

YUSA CORPORATION

Facility ID: 0124010098

Permit Number: P0103947

Permit Type: Initial Installation

Issued: 2/23/2009

Effective: To be entered upon final issuance

Air Pollution Permit-to-Install

for

YUSA CORPORATION

Table of Contents

Authorization

A.Standard Terms and Conditions

1.Federally Enforceable Standard Terms and Conditions

2.Severability Clause

3.General Requirements

4.Monitoring and Related Record Keeping and Reporting Requirements

5.Scheduled Maintenance/Malfunction Reporting

6.Compliance Requirements

7.Best Available Technology

8.Air Pollution Nuisance

9.Reporting Requirements

10.Applicability

11.Construction of New Sources(s) and Authorization to Install

12.Permit-To-Operate Application

13.Construction Compliance Certification

14.Public Disclosure

15.Additional Reporting Requirements When There Are No Deviations of Federally Enforceable Emission Limitations, Operational Restrictions, or Control Device Operating Parameter Limitations

16.Fees

17.Permit Transfers

18.Risk Management Plans

19.Title IV Provisions

B.Facility-Wide Terms and Conditions

C.Emissions Unit Terms and Conditions

1.Emissions Unit Group - Adhesive Applicators K061-K067: K061, K062, K063, K064, K065, K066, K067,

Draft Permit-to-Install

Permit Number: P0103947

Facility ID: 0124010098

Effective Date: To be entered upon final issuance

Authorization

Facility ID: 0124010098

Facility Description: Motor vehicle parts and accessories

Application Number(s): A0035997, A0036408

Permit Number: P0103947

Permit Type: Initial Installation

Permit Fee: $1,400.00 DO NOT send payment at this time, subject to change before final issuance

Issue Date: 2/23/2009

Effective Date: To be entered upon final issuance

This document constitutes issuance to:

YUSA CORPORATION

151 Jamison Rd. SW

Washington Court House, OH 43160

of a Permit-to-Install for the emissions unit(s) identified on the following page.

Ohio EPA District Office or local air agency responsible for processing and administering your permit:

Ohio EPA DAPC, Central District Office

50 West Town Street, 6th Floor

P.O. Box 1049

Columbus, OH 43216-1049

(614)728-3778

The above named entity is hereby granted a Permit-to-Install for the emissions unit(s) listed in this section pursuant to Chapter 3745-31 of the Ohio Administrative Code. Issuance of this permit does not constitute expressed or implied approval or agreement that, if constructed or modified in accordance with the plans included in the application, the emissions unit(s) of environmental pollutants will operate in compliance with applicable State and Federal laws and regulations, and does not constitute expressed or implied assurance that if constructed or modified in accordance with those plans and specifications, the above described emissions unit(s) of pollutants will be granted the necessary permits to operate (air) or NPDES permits as applicable.

This permit is granted subject to the conditions attached hereto.

Ohio Environmental Protection Agency

Chris Korleski

Director

Authorization (continued)

Permit Number:P0103947

Permit Description:Installation of seven new adhesive application machines. Synthetic minor restrictions to use an RTO with PTE are necessary to restrict VOC potential emissions below major NSR thresholds.

Permits for the following Emissions Unit(s) or groups of Emissions Units are in this document as indicated below:

Group Name:Adhesive Applicators K061-K067

Emissions Unit ID: / K061
Company Equipment ID: / Top Hat Adhesive M/C
Superseded Permit Number:
General Permit Category and Type: / Not Applicable
Emissions Unit ID: / K062
Company Equipment ID: / Straight Outer Pipe
Superseded Permit Number:
General Permit Category and Type: / Not Applicable
Emissions Unit ID: / K063
Company Equipment ID: / MT Bracket/T-Rod M/C
Superseded Permit Number:
General Permit Category and Type: / Not Applicable
Emissions Unit ID: / K064
Company Equipment ID: / Upper Bracket/Mushrm
Superseded Permit Number:
General Permit Category and Type: / Not Applicable
Emissions Unit ID: / K065
Company Equipment ID: / Flex A Inner Pipe
Superseded Permit Number:
General Permit Category and Type: / Not Applicable
Emissions Unit ID: / K066
Company Equipment ID: / Straight Outer Pipe2
Superseded Permit Number:
General Permit Category and Type: / Not Applicable
Emissions Unit ID: / K067
Company Equipment ID: / Stopper Bracket
Superseded Permit Number:
General Permit Category and Type: / Not Applicable

A.Standard Terms and Conditions

1.Federally Enforceable Standard Terms and Conditions

a)All Standard Terms and Conditions are federally enforceable, with the exception of those listed below which are enforceable under State law only:

(1)Standard Term and Condition A. 2.a), Severability Clause

(2)Standard Term and Condition A. 3.c) through A. 3.e)General Requirements

(3)Standard Term and Condition A. 6.c) and A. 6.d), Compliance Requirements

(4)Standard Term and Condition A. 9., Reporting Requirements

(5)Standard Term and Condition A. 10., Applicability

(6)Standard Term and Condition A. 11.b) through A. 11.e), Construction of New Source(s) and Authorization to Install

(7)Standard Term and Condition A. 14., Public Disclosure

(8)Standard Term and Condition A. 15., Additional Reporting Requirements When There Are No Deviations of Federally Enforceable Emission Limitations, Operational Restrictions, or Control Device Operating Parameter Limitations

(9)Standard Term and Condition A. 16., Fees

(10)Standard Term and Condition A. 17., Permit Transfers

2.Severability Clause

a)A determination that any term or condition of this permit is invalid shall not invalidate the force or effect of any other term or condition thereof, except to the extent that any other term or condition depends in whole or in part for its operation or implementation upon the term or condition declared invalid.

b)All terms and conditions designated in parts B and C of this permit are federally enforceable as a practical matter, if they are required under the Act, or any its applicable requirements, including relevant provisions designed to limit the potential to emit of a source, are enforceable by the Administrator of the U.S. EPA and the State and by citizens (to the extent allowed by section 304 of the Act) under the Act. Terms and conditions in parts B and C of this permit shall not be federally enforceable and shall be enforceable under State law only, only if specifically identified in this permit as such.

3.General Requirements

a)The permittee must comply with all terms and conditions of this permit. Any noncompliance with the federally enforceable terms and conditions of this permit constitutes a violation of the Act, and is grounds for enforcement action or for permit revocation, revocation and re-issuance, or modification.

b)It shall not be a defense for the permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the federally enforceable terms and conditions of this permit.

c)This permit may be modified, revoked, or revoked and reissued, for cause. The filing of a request by the permittee for a permit modification, revocation and reissuance, or revocation, or of a notification of planned changes or anticipated noncompliance does not stay any term and condition of this permit.

d)This permit does not convey any property rights of any sort, or any exclusive privilege.

e)The permittee shall furnish to the Director of the Ohio EPA, or an authorized representative of the Director, upon receipt of a written request and within a reasonable time, any information that may be requested to determine whether cause exists for modifying or revoking this permit or to determine compliance with this permit. Upon request, the permittee shall also furnish to the Director or an authorized representative of the Director, copies of records required to be kept by this permit. For information claimed to be confidential in the submittal to the Director, if the Administrator of the U.S. EPA requests such information, the permittee may furnish such records directly to the Administrator along with a claim of confidentiality.

4.Monitoring and Related Record Keeping and Reporting Requirements

a)Except as may otherwise be provided in the terms and conditions for a specific emissions unit, the permittee shall maintain records that include the following, where applicable, for any required monitoring under this permit:

(1)The date, place (as defined in the permit), and time of sampling or measurements.

(2)The date(s) analyses were performed.

(3) The company or entity that performed the analyses.

(4)The analytical techniques or methods used.

(5)The results of such analyses.

(6)The operating conditions existing at the time of sampling or measurement.

b)Each record of any monitoring data, testing data, and support information required pursuant to this permit shall be retained for a period of five years from the date the record was created. Support information shall include, but not be limited toall calibration and maintenance records and all original strip-chart recordings for continuous monitoring instrumentation, and copies of all reports required by this permit. Such records may be maintained in computerized form.

c)Except as may otherwise be provided in the terms and conditions for a specific emissions unit, the permittee shall submit required reports in the following manner:

(1)Reports of any required monitoring and/or recordkeeping of federally enforceable information shall be submitted to the Ohio EPA DAPC, Central District Office.

(2)Quarterly written reports of (i) any deviations from federally enforceable emissionlimitations, operationalrestrictions, andcontroldeviceoperatingparameterlimitations, excluding deviations resulting from malfunctions reported in accordance with OAC rule 3745-15-06, that have been detected by the testing, monitoring and recordkeeping requirements specified in this permit, (ii) the probable cause of such deviations, and (iii) any corrective actions or preventive measures taken, shall be made to the Ohio EPA DAPC, Central District Office. The written reports shall be submitted (i.e., postmarked) quarterly, by January 31, April 30, July 31, and October 31 of each year and shall cover the previous calendar quarters. See A.15. below if no deviations occurred during the quarter.

(3)Written reports, which identify any deviations from the federally enforceable monitoring, recordkeeping, andreportingrequirements contained in this permit shall be submitted (i.e., postmarked) to the Ohio EPA DAPC, Central District Office every six months, by January 31 and July 31 of each year for the previous six calendar months. If no deviations occurred during a six-month period, the permittee shall submit a semi-annual report, which states that no deviations occurred during that period.

(4)This permit is for an emissions unit located at a Title V facility. Each written report shall be signed by a responsible official certifying that, based on information and belief formed after reasonable inquiry, the statements and information in the report are true, accurate, and complete.

d) The permittee shall report actual emissions pursuant to OAC Chapter 3745-78 for the purpose of collecting Air Pollution Control Fees.

5.Scheduled Maintenance/Malfunction Reporting

Any scheduled maintenance of air pollution control equipment shall be performed in accordance with paragraph (A) of OAC rule 3745-15-06. The malfunction, i.e., upset, of any emissions units or any associated air pollution control system(s) shall be reported to the Ohio EPA DAPC, Central District Office in accordance with paragraph (B) of OAC rule 3745-15-06. (The definition of an upset condition shall be the same as that used in OAC rule 3745-15-06(B)(1) for a malfunction.) The verbal and written reports shall be submitted pursuant to OAC rule 3745-15-06.